FAQ – Executive Orders and other Federal Agency Actions

The university has a team of senior leaders and experts that evaluates relevant executive orders and agency actions to ensure we are in compliance with the law while staying true to our mission.

The university recently posted this website, which will continue to be updated as the situation evolves.

We are conducting this review to clarify the intent of our programs and practices, strengthen their effectiveness, and ensure alignment with our compliance obligations in light of recent executive orders and agency guidance.

Yes. Each heritage month or day that we celebrate is officially recognized at the national level either through a U.S. presidential proclamation or Congressional resolution.

In fiscal year 2024, USC received about $1.35 billion in federal funding, including $569 million for federally funded research and about $650 million in student financial assistance, which includes Direct Student Loans, Pell Grants, Work-Study Programs, and Federal Perkins Loans. The other funding was related to other federal programs, such as Head Start and FEMA. This does not include amounts received by the Health System for providing patient care under the Medicare or Medi-Cal programs.

Noncompliance with federal regulations and laws could potentially lead to the termination of federally funded research projects and disqualification from submitting new research proposals.

So far, student financial assistance programs have not been explicitly addressed in the executive orders.

The university has not received any termination or stop work notices on federal contracts or grants, except for a pause on four projects involving the Department of State and the Department of Transportation.

On February 10, 2025, a federal court issued a nationwide temporary restraining order enjoining the NIH from taking any steps to implement, apply, or enforce its new standard 15 percent indirect cost rate.

In response, on February 12, NIH leadership authorized NIH staff to proceed with issuing new and continuing grants under current funding policies, including previously approved negotiated indirect cost rates, until further notice. No funding cuts have been formalized publicly as of now, other than for specific projects with aims that conflict with the executive orders.

Almost all global health programs are funded through foreign aid appropriations that are subject to an executive order temporarily freezing any new U.S. government spending through these programs. This may interrupt implementation of programs for which funds have not yet been obligated.

Other recent executive orders that could potentially affect research awards from the NIH or other federal agencies include Executive Order 14168 (“Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government”). and Executive Order 14187 (“Protecting Children From Chemical and Surgical Mutilation”). On February 13, 2025, a federal court issued a temporary restraining order enjoining the federal government from conditioning or withholding federal funding on the basis that a healthcare entity provides gender affirming care to a patient under age 19.

PIs should continue to develop proposals and submit them. For new and continuing proposals, they should continue to use our federally negotiated rate agreements to build budgets.

Researchers must still adhere to existing regulations for the protection of human subjects.

If you believe the specific aims of your active federal award may not comply with the executive orders, consult with your program officer or institutional partner for guidance.If you believe the specific aims of your active federal award may not comply with the executive orders, consult with your program officer or institutional partner for guidance.

If you are advised to stop work on an active award, in whole or in part, please inform your Department of Contracts and Grants Officer immediately.

If you are unsure how to proceed, reach out to your School Research Administration team and/or your Department of Contracts and Grants Officer directly to discuss your specific situation.

The university’s Policy on Responding to Immigration Enforcement Actions provides direction to faculty, staff, and other covered personnel (as defined in the policy) regarding how to address immigration enforcement activities that may occur at USC consistent with federal and state law.

Refer to the USC Gould School of Law Immigration Clinic’s Know Your Rights information or contact ILAC at (213) 821-9627 for legal advice.

In accordance with both state law and the university’s Policy on Responding to Immigration Enforcement Actions, if any faculty, staff, or other covered personnel (as defined in the policy) becomes aware or has reason to suspect that (1) a government official, including a law enforcement officer, engaged in immigration enforcement is expected to enter, will enter, or has entered University Premises for immigration enforcement purposes, or (2) a student or employee may have been taken into custody as the result of an immigration enforcement action, they should immediately contact the main Department of Public Safety (DPS) phone line at (213) 740-6000 and provide a detailed explanation of the situation. DPS will notify the appropriate university officials.

Note: Faculty, staff, and other covered personnel should not take any action to intentionally conceal or harbor an individual in violation of the Immigration and Nationality Act or other federal immigration laws, or to intentionally obstruct lawful immigration enforcement activities.

Follow the University and Health System Protocol When Presented With a Warrant or Government Subpoena (the “OGC Protocol”) issued by the Office of the General Counsel:

1. Initial Response – ask the individual presenting the warrant or government subpoena for their contact information, and request permission to photograph their government credentials.
2. Explain Legal Representation – politely inform them that the university is represented by the Office of the General Counsel, and that all warrants and government subpoenas must first be reviewed by OGC.
3. Refer the Individual to OGC Without Accepting or Providing Information – refer the individual to the Office of the General Counsel without accepting documents, and/or releasing any documents, records, or other information (even if deemed “directory information” under FERPA). OGC can be reached by phone at (213) 740-7922 or by email at gcoffice@usc.edu.
4. Do Not Attempt to Physically Block or Interfere with Agent – do not attempt to physically block or interfere with the agent in the unlikely event that they refuse to follow your direction.
5. Immediately Contact DPS – use the main DPS phone line 213-740-6000 (24/7) to provide a detailed explanation of the situation, so that DPS can immediately inform the appropriate individuals.

As noted in the OGC Protocol, if a government official, including an immigration officer, refuses to follow your direction to present their warrant/subpoena to OGC, you should not physically obstruct or interfere with the government official. Immediately contact DPS at 213-740-6000 and provide a detailed explanation of the situation.

Review the Know Your Rights information posted on the USC Gould Immigration Clinic’s Immigrant Legal Assistance Center (ILAC) website.

In accordance with state law, USC has designated Niels W. Frenzen, Esq., Co-Director of the USC Gould Immigration Clinic, as the point of contact for any student or employee who may or could be subject to an immigration order or inquiry. Urgent immigration enforcement matters should be reported to ILAC’s Emergency Arrest Hotline at (213) 740-7435. Non-urgent inquiries should be made to ILAC at (213) 821-9627. Professor Frenzen may be reached by phone at (213) 740-8933 or email at nfrenzen@law.usc.edu.

In accordance with state law and the university’s Policy on Responding to Immigration Enforcement Actions, all faculty, staff, and other covered personnel are required to immediately contact DPS at (213) 740-6000 if they become aware that a student or employee may have been taken into custody as the result of an immigration enforcement action. DPS will inform the appropriate campus officials and the individual’s emergency contact will be notified and provided with information about ILAC’s Emergency Arrest Hotline.

The USC community has access to a wide range of private and confidential resources to address concerns or issues. A list of resources is posted on the Report & Response website.

The ILAC office is located in the Immigration Clinic at the Gould School of Law, 699 Exposition Boulevard, Los Angeles, CA 90089-0071.

International students and scholars attending USC on F-1 and J-1 visas can meet with an advisor in the Office of International Services without an appointment by attending OIS Drop-in Advising. OIS can also be reached by email at ois@usc.edu (for general and F-1 student-related inquiries), j1scholar@usc.edu (for J-1 scholar-related inquiries) or j1student@usc.edu (for J-1 student-related inquiries).

Faculty/Staff Visa Services (FSVS) provides work-related immigration services for departments across the university. Foreign nationals employed at USC on a work visa with questions about their status may schedule an appointment with FSVS by emailing fsvs@usc.edu or calling (213) 740-5257.

Students and scholars at risk around the world can visit the USC Hub to explore resources and potential academic opportunities at the university.

Refer to ILAC’s Know Your Rights information or contact ILAC at (213) 821-9627 for legal advice.